Hatfield v. Commissioner’s Empirical Analysis

Citation profile

1 district ·

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 2 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “* * * * * * * “Petitioner suggests that the failure of Congress to adopt more restrictive language should be taken as an indication of its purpose to include only ‘legislative’ and ‘constitutional’ judges taking office subsequent to the specified date. He suggests that the use of some such language as ‘in the case of Presidents of the United States and judges of inferior courts of the United States taking office after the date of enactment of this Act’ would have placed the matter beyond question. In this we think he overlooks the fact that the sentence we are discussing is a taxing provision and not one of exemption. It was therefore reasonable and appropriate for Congress to indicate the breadth of its purpose by using language as general and unrestricted as possible. For example, had the words suggested by petitioner been used, application of the very rule for which he contends would have made it possible to argue that, since Congress specified as taxable only the salaries of ‘constitutional’ judges, the salaries of ‘legislative’ judges would consequently have been exempt, not only as to those taking office prior to 1932 but as to the entire class.””

   1 later decision quote this exact passage
   e.g. Brown v. Magruder